52893

Rules and Regulations Federal Register

Vol. 70, No. 171

Tuesday, September 6, 2005

This section of the FEDERAL REGISTER
contains regulatory documents having general
applicability and legal effect, most of which
are keyed to and codified in the Code of
Federal Regulations, which is published under
50 titles pursuant to 44 U.S.C. 1510.
The Code of Federal Regulations is sold by
the Superintendent of Documents. Prices of
new books are listed in the first FEDERAL
REGISTER issue of each week.
NUCLEAR REGULATORY
COMMISSION
10 CFR Part 50
[Docket No. PRM–50–76]
Robert H. Leyse; Denial of Petition for
Rulemaking
AGENCY: Nuclear Regulatory
Commission.
ACTION: Petition for rulemaking; denial.
SUMMARY: The Nuclear Regulatory
Commission (NRC) is denying a petition
for rulemaking submitted by Mr. Robert
H. Leyse (PRM–50–76). The petitioner
requests that the NRC’s regulations
concerning the specified evaluation
models for emergency core cooling
systems (ECCS) and associated guidance
documents be amended. The petitioner
asserts that amendments are necessary
to correct technical deficiencies in the
correlations and data used for
calculation of metal-water oxidation.
The petitioner states that the
correlations and data do not consider
the complex thermal-hydraulic
conditions present during a loss-of-
coolant accident (LOCA), including the
potential for very high fluid
temperature. The Commission is
denying Mr. Leyse’s petition for
rulemaking (PRM–50–76). None of the
specific technical issues raised by the
petitioner have shown safety-significant
deficiencies in the research, calculation
methods, or data used to support ECCS
performance evaluations. NRC’s
technical safety analysis demonstrates
that current procedures for evaluating
ECCS performance are based on sound
science and that no amendments to the
NRC’s regulations and guidance
documents are necessary.
ADDRESSES: The NRC is making the
documents identified in the table below
available to interested persons through
several means. Publicly available
documents related to this petition,
including the petition for rulemaking,
public comments received, and the
NRC’s letter of denial to the petitioner,
may be viewed electronically on public
computers in the NRC’s Public
Document Room (PDR), O–1 F21, One
White Flint North, 11555 Rockville
Pike, Rockville, Maryland 20852. The
PDR reproduction contractor will copy
documents for a fee. Selected
documents, including comments, may
be viewed and downloaded
electronically via the NRC rulemaking
Web site at http://ruleforum.llnl.gov.
Publicly available documents created
or received at the NRC after November
1, 1999, are also available electronically
at the NRC’s Electronic Reading Room at
http://www.nrc.gov/reading-rm/
adams.html. From this site, the public
can gain access into the NRC’s
Agencywide Documents Access and
Management System (ADAMS), which
provides text and image files of NRC’s
public documents. If you do not have
access to ADAMS or if you have
problems in accessing the documents in
ADAMS, contact the PDR reference staff
at (800) 387–4209 or (301) 415–4737 or
by e-mail to pdr@nrc.gov.

Document PDR Web ADAMS

Federal Register Notice—Receipt of Petition for Rulemaking (67 FR 51783; Aug. 9, 2002) .............................. X X ML022800472
Letter of Denial to the Petitioner ............................................................................................................................. X X ML052220454
Penn State/US NRC ‘‘Rod Bundle Test Facility and Reflood Heat Transfer Program’’ ........................................ ML023040657
Petition for Rulemaking (PRM–50–76) ................................................................................................................... X X ML022240009
Public Comments for PRM–50–76 ......................................................................................................................... X X ML042740105
US NRC Office of Nuclear Research (RES) ‘‘Technical Safety Analysis of PRM–50–76, A Petition for Rule- X X ML041210109
making to Amend Appendix K to 10 CFR Part 50 and Regulatory Guide 1.157’’.
US NRC, ‘‘Updated Program Plan for High-Burnup Light-Water Reactor Fuel’’ ................................................... .......... .......... ML031810103
Studies of Metal Water Reactions at High Temperatures, III. Experimental and Theoretical Studies of the Zir- .......... .......... ML050550198
conium-Water Reaction,’’ L. Baker and L.C. Just, ANL–6548 (May 1962).
PWR FLECHT (Full Length Emergency Cooling Heat Transfer) Final Report,’’ April 1971 .................................. .......... .......... ML052230221
Zirconium Metal-Water Oxidation Kinetics IV. Reaction Rate Studies,’’ ORNL/NUREG–17, August 1977. ......... .......... .......... ML052230079

FOR FURTHER INFORMATION CONTACT: (67 FR 51783). The notice of receipt Commission’s regulations, (2) amending
Timothy A. Reed, Office of Nuclear requested comment on two questions: Regulatory Guide (RG) 1.157, and (3) the
Reactor Regulation, U.S. Nuclear (1) Are the petitioner’s three concerns need for further analysis of the 10 CFR
Regulatory Commission, Washington, about ECCS cooling valid, and if so, do Part 50, Appendix K, backup data.
DC 20555–0001, telephone (301) 415– these concerns constitute a significant
Issue 1: Amending Appendix K to Part
1462, e-mail TAR@nrc.gov. safety concern? (2) Are there actions
50
SUPPLEMENTARY INFORMATION: available to the Commission other than
rulemaking that would effectively The petitioner describes at length
Background address the concerns raised by the alleged technical deficiencies in
The petition for rulemaking petitioner? Appendix K Section I.A.5, ‘‘Metal-Water
designated PRM–50–76 was received by The Petition Reaction Rate.’’ The petitioner claims
the NRC on May 1, 2002. A notice of that Section I.A.5 does not accurately
receipt of the petition and request for The petition, PRM–50–76, covers describe the extent of zirconium-water
public comment was published in the three broad issues: (1) Amending reactions that may occur during a
Federal Register (FR) on August 9, 2002 Appendix K to Part 50 of the LOCA. The petitioner states that the

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 52894 Federal Register / Vol. 70, No. 171 / Tuesday, September 6, 2005 / Rules and Regulations
Baker-Just equation, which is used to
calculate the metal-water reaction in
assessing ECCS performance, does not
include any allowance for the complex
thermal-hydraulic conditions during a
LOCA, including the potential for very
high bulk fluid temperatures within the
cooling channels of the zirconium-clad
fuel elements.
The petitioner cites the abstract of an
Argonne National Laboratory (ANL)
report (ANL–6548 ‘‘Studies of Metal
Water Reactions at High Temperatures,
III. Experimental and Theoretical
Studies of the Zirconium-Water
Reaction,’’ L. Baker and L.C. Just, May
1962) and disputes the conclusions
based on the petitioner’s opinion that
the tests discussed in ANL–6548 do not
accurately reflect the conditions present
during a LOCA. The petitioner makes
the following points to support his
views:
• The bulk water temperature was no
greater than 315 °C (599 °F).
• The volume of water within the test
apparatus was substantially greater than
the volume of zirconium specimens,
creating a vastly greater capacity to cool
the heated zirconium particles of the
Baker and Just experiment than would
exist under LOCA conditions.
• Zirconium specimens were exposed
to water only, while LOCA conditions
include steam and nonequilibrium
water-steam mixtures that reached
higher bulk fluid temperatures.
• A footnote in ANL–6548 states:
‘‘This discussion is of a preliminary
nature: work in this area is continuing.’’
Based on this footnote, the petitioner
concludes that it is not appropriate to
apply the Baker-Just equation as
prescribed in Appendix K Section I.A.5
for the calculation of energy release
rates, hydrogen generation, and
cladding oxidation from the metal-water
reaction.
Issue 2: Amending Regulatory Guide
1.157
The petitioner states that RG 1.157,
which allows use of data from NUREG–
17 (ORNL/NUREG–17, ‘‘Zirconium
Metal-Water Oxidation Kinetics IV,
Reaction Rate Studies,’’ by Cathcart et
al., August 1977) for calculating energy
release rates, hydrogen generation, and
cladding oxidation for cladding
temperatures greater than 1900 °F,
results in flawed ECCS performance
evaluations. The petitioner claims the
NUREG–17 data is based on very
limited test conditions and
consequently the results should not be
used for evaluating LOCA conditions.
In support of this contention, the
petitioner describes the following test
conditions:
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• Zircaloy-4 specimens exposed only
to steam, rather than fluid conditions as
present in a LOCA.
• No documented heat transfer from
the Zircaloy surface to the slow-flowing
steam.
• Small-scale laboratory testing
without conditions typical of the
complex thermal-hydraulic conditions
that prevail during a LOCA.
• An unexplained shift from the
MaxiZWOK (testing apparatus for
investigations in the temperature range
1652 °F to 1832 °F) to the MiniZWOK
(a different testing apparatus for
investigations in the temperature range
1832 °F to 2734 °F).
The petitioner believes that the
investigators’ conclusions include a
statement that ‘‘overlooks the very
substantially greater mass transfer
coefficients that accompany the so-
called appropriate heat transfer
coefficients.’’ The petitioner concludes
that ‘‘it is those very substantially
greater mass transfer coefficients that
led to the temperature overshoot of the
MaxiZWOK test at 1832 °F, and that
would have led to very substantially
greater temperature overshoots and
likely destruction of the Zircaloy tubing
if MaxiZWOK had been operated over
the temperature range of the MiniZWOK
runs.’’
The petitioner contends that the
NUREG–17 investigators do not warrant
their work, and specifically assume no
responsibility for the accuracy of their
work, and therefore, that NUREG–17 is
not applicable to the regulation of
nuclear power reactors in the United
States of America. To support this
contention, the petitioner cites the
following statement on the introductory
page of NUREG–17: This report was
prepared as an account of work
sponsored by the United States
Government. Neither the United States
nor the Energy Research and
Development Administration/United
States Nuclear Regulatory Commission,
nor any of their employees, nor any of
their contractors, subcontractors, or
their employees, makes any warranty,
express or implied, or assumes any legal
liability or responsibility for the
accuracy, completeness or usefulness of
any information, apparatus, product or
process disclosed, or represents that its
use would not infringe privately owned
rights.’’
Issue 3: Need for Further Analysis of
Appendix K Backup Data
The petitioner states that the results of
Zircaloy bundle test no. 9573, which
was a test done for the Full Length
Emergency Cooling Heat Transfer
(FLECHT) tests and documented in
PO 00000 Frm 00002 Fmt 4700 Sfmt 4700 E:\FR\FM\06SER1.SGM
WCAP–7665 (‘‘PWR FLECHT (Full
Length Emergency Cooling Heat
Transfer) Final Report, Westinghouse
Report WCAP–7665, April 1971’’), are
applicable to the calculation of the
metal-water reaction and shows that the
Baker-Just equation (referenced in
Section I.A.5 of Appendix K for
calculating the metal-water reaction) is
not conservative. The petitioner states
that the data in WCAP–7665, which
includes test run 9573, includes the
complex thermal-hydraulic conditions
and Zircaloy-water reactions that
characterize the reflood portion of the
LOCA transient. The petitioner states
that these conditions are not found in
the narrow test procedures of ANL–6548
or NUREG–17.
The petitioner states that a pertinent
description of the complexities of
thermal-hydraulic conditions during
reflood, including negative heat transfer
coefficients, is included in Section 3.2.3
of WCAP–7665 and that this description
applies to data collected with FLECHT
bundles with stainless steel cladding.
The petitioner feels that another
FLECHT Zircaloy bundle test, run 8874,
is also pertinent to issues raised in this
petition.
The petitioner cites Section 5.6 of
WCAP–7665 and finds statements
comparing Zircaloy to stainless steel to
be misleading because they imply that
stainless steel heat transfer coefficients
may be used as a conservative
representation of Zircaloy behavior. The
petitioner believes that the differences
in behavior for various test runs are
explained by the differences in the
thermal-hydraulic conditions leading to
a different combination of heat transfer
and mass transfer factors, and are not
due to inconsistency of the data, as
implied by the report.
The petitioner also finds WCAP–7665,
Section 5.11, ‘‘Materials Evaluation,’’ to
be misleading in view of the total
experience with FLECHT run 9573.
Finally, the petitioner notes that the
same warning language used in
NUREG–17 is on the cover page of
WCAP–7665.
The petitioner further identifies
several aspects of the data supporting
the document entitled ‘‘Acceptance
Criteria for Emergency Core Cooling
Systems for Light-Water Cooled Nuclear
Reactors-Opinion of the Commission,’’
(Docket No. RM50–1, December 28,
1973) and notes the Commission
concluded: ‘‘It is apparent, however,
that more experiments with Zircaloy
cladding are needed to overcome the
impression left from run 9573.’’ The
petitioner finds that there has been a
lack of appropriate response to the
Commission’s expressed wish for more
06SER1
 Federal Register / Vol. 70, No. 171 / Tuesday, September 6, 2005 / Rules and Regulations
experiments, and believes that at the
very least, run 9573 should have been
repeated. The petitioner emphasizes
that although at least $1 billion had
been expended on other analytical
efforts, there has been no reported
analysis of FLECHT run 9573.
The petitioner states that the test
programs discussed in the petition were
funded by Government agencies. He
believes that most of the programs were
firmly controlled by those ‘‘who were
indoctrinated in the methods of the
tightly regimented Naval Reactors
Program.’’ The petitioner finds that the
‘‘biased reporting of WCAP–7665 may
be traced to these controls’’ and believes
that ‘‘the lack of application of the
MaxiZWOK apparatus beyond 1832 °F
in NUREG–17 may likely be traced to
rigid restrictions by management at the
NRC.’’ The petitioner further contends
that while the Argonne work in ANL–
6548 was likely less impacted by these
controls, the controls likely did inhibit
further analysis or reporting of FLECHT
run 9573.
The petitioner notes that he has made
several requests to the Knolls Atomic
Power Laboratory for report KAPL–1534
and that his requests have been ignored.
Public Comments on the Petition
Six letters of public comment were
received on the petition in response to
the request for public comment. Three
of these letters were from the petitioner.
These letters are summarized below.
By letter dated September 11, 2002,
the petitioner provided comments that
did not raise new issues. The petitioner
stated that the Baker-Just equation and
the Cathcart-Pawel equation in NUREG–
17 have been grossly misapplied by the
NRC. According to him, it is
fundamentally important that the
determinations of LOCA transient
chemical kinetics include the geometry
of the stationary Zircaloy reactant in
combination with the thermal-hydraulic
conditions of the flowing water/steam
reactant. In addition, he repeated in his
letter that there are deficiencies in RG
1.157, since it references documents
such as NUREG–17 that do not consider
the complex thermal-hydraulic
conditions during LOCAs, including the
potential for very high fluid
temperatures. The petitioner also stated
that the Commission should provide a
rational basis for regulation of ECCS
performance and perform additional
experiments with Zircaloy cladding due
to the cladding failure reported in
Westinghouse report WCAP–7665.
By letter dated October 23, 2002,
Westinghouse Electric Company
submitted comments that opposed the
proposed changes. Westinghouse
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commented that runaway oxidation is
prevented by the 2200 °F peak cladding
temperature limit. Additionally,
Westinghouse commented that the
Baker-Just correlation is known to be
conservative, over-predicting the
zirconium-water reaction by as much as
30 percent at the limiting temperature
(2200 °F). Westinghouse stated that the
conditions of FLECHT run 9573 (high
power and high initial temperatures)
were extremely severe, intentionally
beyond design basis for ECCS
performance. Westinghouse stated that
the Cathcart-Pawel tests had adequate
steam flow so that the zirconium-water
reaction rate was not limited by the
availability of steam, and as a result, the
tests were valid. Westinghouse
commented that differences between
ECCS test conditions and reactor core
fluid conditions during postulated
LOCAs do not prevent the current
zirconium-water reaction database from
being applicable to ECCS analysis.
By letter dated October 25, 2002, the
Nuclear Energy Institute (NEI)
submitted comments supporting the
Westinghouse comments, stating that
extensive testing and analysis by the
nuclear industry and national
laboratories indicate that the Cathcart-
Pawel correlation test is conservative.
The NRC notes that the Cathcart-Pawel
correlation is intended to be a best
estimate, and is not intended to
conservatively bound metal-water
reaction rates. NEI commented that the
test run, FLECHT 9573, was
intentionally performed under very
severe, beyond design-basis conditions,
that post-test evaluations showed
oxidation was within the expected
range, and that runaway oxidation did
not occur until the cladding temperature
was well beyond 2300 °F. NEI further
commented that the petitioner’s
concerns do not constitute a significant
safety concern and thus, there is no
need to revise Appendix K to Part 50 or
RG 1.157.
By letter dated November 6, 2002,
Strategic Teaming and Resource Sharing
(STARS), a group of six utilities,
submitted comments opposing the
petition. These comments stated that
within the range of test parameters
applicable to ECCS evaluation models,
as specified in Appendix K and RG
1.157, the regulations and guidance are
valid and conservative. STARS notes
that all of the data referenced in the
petition was either available to the
Commission and industry when the
regulations and guidance were created
or was assessed later when the test
information became available.
On November 22, 2002, the petitioner
submitted a reply to STARS but raised
PO 00000 Frm 00003 Fmt 4700 Sfmt 4700
52895
no new issues. On December 14, 2002,
the petitioner responded to
Westinghouse and NEI comments by
discussing runaway oxidation in the
WCAP–12610 report and severe fouling
of fuel cladding during a LOCA. The
petitioner stated that no allowance for
higher temperatures due to fouling was
made in run 9573, and repeated his
request for more experiments with
Zircaloy cladding.
NRC Requirements for ECCS
Evaluations
Section 50.46 specifies the
performance criteria against which the
ECCS must be evaluated. The criteria
include the maximum peak cladding
temperature, the maximum cladding
oxidation thickness, the maximum total
hydrogen generation, and requirements
to assure a coolable core geometry and
abundant long-term cooling. This
regulation also states that the ECCS
cooling performance following
postulated LOCAs must be calculated in
accordance with either a realistic (also
called a best-estimate) evaluation model
that accounts for uncertainty or a
conservative evaluation model that
conforms with the required features of
appendix K to 10 CFR part 50. If a
licensee elects to calculate ECCS
performance using an Appendix K
evaluation model, then one important
feature of that model is the way the
metal-water reaction is calculated. For
this calculation, Appendix K prescribes
the use of the Baker-Just equation from
ANL report ANL–6548 (L. Baker, L.C.
Just, ‘‘Studies of Metal Water Reactions
at High Temperatures, III. Experimental
and Theoretical Studies of the
Zirconium-Water Reaction’’ May 1962).
The metal-water reaction, which is
predicted to occur during the LOCA and
which is calculated using the Baker-Just
equation, is the subject of much of this
petition. The Baker-Just equation
calculates a conservative rate of
hydrogen generation and fuel cladding
oxidation during the LOCA transient.
Additionally, for licensees electing to
use best-estimate calculations to
evaluate ECCS performance, NRC RG
1.157 provides guidance for such
evaluations. RG 1.157 allows the use of
data from NUREG–17 for the calculation
of the metal-water reaction.
NRC Technical Evaluation
The NRC reviewed the petitioner’s
request and concluded that none of the
issues raised by the petitioner justified
the initiation of rulemaking. The NRC’s
response to the technical issues raised
in PRM–50–76 is based largely on a
technical study by the Office of Nuclear
Regulatory Research (RES) ‘‘Technical
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 52896 Federal Register / Vol. 70, No. 171 / Tuesday, September 6, 2005 / Rules and Regulations
Safety Analysis of PRM–50–76, A
Petition for Rulemaking To Amend
appendix K to 10 CFR part 50 and
Regulatory Guide 1.157.’’ The NRC’s
responses to the petitioner’s issues are
as follows:
Issue 1: Amending Appendix K to Part
50
The petitioner claims that the
requirement to use the Baker-Just
equation in Section I.A.5 of Appendix K
to 10 CFR Part 50, does not accurately
describe the extent of zirconium-water
reaction that may occur during a LOCA.
He states that the Baker-Just equation
does not include any allowance for the
complex thermal-hydraulic conditions
during a LOCA. The NRC disagrees with
the petitioner’s assertions.
In Section 3.1 of the petition, the
petitioner discusses the inapplicability
of the Baker-Just equation for
calculating zirconium-water reaction
rates during a LOCA. The NRC notes
that it is important to distinguish
between the experiments performed by
Baker and Just, and the equation
developed by them and adopted in
Appendix K to Part 50. Experiments run
with 40–60 mil wires at temperatures at,
or near, the zirconium melting point
(3400 °F) for one or two seconds are not
typical of fuel rod cladding at
temperatures in the range of 1800 °F–
2200 °F for 50 to 400 seconds that are
postulated to occur in a design basis
LOCA. In the Baker-Just report, only one
data point from their experiments (at
3366 °F) is used in developing the
Baker-Just equation. This one data point
was used to anchor the Baker-Just
equation at the melting point of
zirconium. The remaining data from
Bostrum (‘‘The High Temperature
Oxidation of Zircaloy in Water,’’ W. A.
Bostrum, WAPD–104 March 1954) and
Lemmon (‘‘Studies Relating to the
Reaction Between Zirconium and Water
at High Temperatures,’’ A. W. Lemmon,
Jr., BMI–1154, January 1957), at more
relevant zirconium cladding conditions,
were used by Baker and Just in the
derivation of their equation. The use of
the single data point at the melting
temperature makes the Baker-Just
equation very conservative. At the time
of the promulgation of § 50.46, the
Commission expected the NRC staff to
obtain new and better zirconium-water
reaction data. The petitioner also
expressed concerns about the need for
additional data. The substantial work of
Cathcart and Pawel was performed for
the NRC in response to the
Commission’s expectation.
The NRC compares the Baker-Just
correlation to other correlations in a
technical study (ADAMS accession
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ML041210109). The comparisons show
the conservatism of the Baker-Just
correlation in the temperature range
important for clad oxidation
calculations for LOCAs. In the
discussion of Issue 3, comparisons of
the Baker-Just correlation to relevant
data demonstrate the substantial
conservatism of the Baker-Just
correlation. The petitioner expresses
concern about the low water
temperature (no greater than 599 °F) in
the Baker-Just experiments. This
temperature corresponds to the
saturation temperature at 1530 psia,
which was the pressure for that
particular experiment. While a few
degrees of liquid superheat may be
possible under LOCA/ECCS conditions,
the degree of nonequilibrium required
for higher liquid or ‘‘bulk’’ temperatures
postulated by the petitioner is not
possible.
The petitioner is also concerned about
the large water volume compared to the
zirconium sample size with respect to
the quench capability of zirconium-clad
fuel rods. As noted, these experiments
were atypical in that respect, but barely
used in the formulation of the Baker-Just
correlation. Further, it should be noted
that the Baker-Just report was not
intended to be a heat transfer study, but
rather an investigation of zirconium-
water reaction kinetics at very high
temperatures.
One interesting feature of the Baker-
Just report is the heat and mass transfer
analysis of an example case analyzed to
examine the processes limiting the
reaction rate. In this severe case, a 0.21
cm zirconium sphere at its melting
point was dropped into water. Baker
andJust were concerned that the
reaction could be limited by gas phase
diffusion of steam through a film of
steam and hydrogen. This appears to be
similar to the petitioner’s concern. As
explained in the Baker-Just report, water
cannot stay in contact with the hot
metal and a vapor film immediately
forms around the sphere. Figure 15 in
that report shows that vapor phase
diffusion is the limiting steam transport
process for less than 0.2 seconds, during
which a slight film of oxide is forming
on the surface of the sphere. After that,
the parabolic rate equation, (e.g., the
Baker-Just equation) becomes limiting.
The figure also shows that the gas phase
diffusion is far less temperature-
sensitive than the parabolic rate law.
Certainly at lower temperatures more
typical of a LOCA, the parabolic law is
even more limiting than gas phase
diffusion as long as the reaction is not
steam starved.
Comparison of the Baker-Just equation
to numerous data sets has shown the
PO 00000 Frm 00004 Fmt 4700 Sfmt 4700 E:\FR\FM\06SER1.SGM
equation to be conservative. A
significant example of this conservatism
is discussed under Issue 3.
In summary, the NRC found no
technical basis in the petition or in NRC
records for the assertion that the NRC
requirement to use the Baker-Just
equation, along with other requirements
of Appendix K, is flawed and is a
significant safety concern.
Issue 2: Amending Regulatory Guide
1.157
The petitioner stated that RG 1.157,
which allows use of the data and the
Cathcart-Pawel equation presented in
NUREG–17, results in flawed
evaluations of ECCS performance. The
NRC disagrees with the petitioner’s
assertions on this issue. In Section 3.2
of the petition, the petitioner states that
the limited test conditions described in
NUREG–17 preclude the use of the
results for LOCA calculations. He
further states that Zircaloy-4 specimens
were not exposed to LOCA fluid
conditions and that only steam was
applied at very low velocities for the
main test series. The petitioner states
that there was no documented heat
transfer from the Zircaloy surface to the
slow-flowing steam and that as a result
the conditions of the small-scale
laboratory tests were not typical of the
complex thermal-hydraulic conditions
that prevail during a LOCA.
The petitioner suggests that without
liquid water, the tests are invalid. The
NRC disagrees. The presence of liquid
water would invalidate the tests.
Accurate steady-flow measurement
would be extremely difficult. The
droplets or liquid film would make it
difficult to achieve the relatively
constant sample temperatures that are
necessary in these reaction kinetics
tests. However, adequate steam flow is
a concern. If the flow is too low, the
reaction becomes steam starved.
Otherwise, it is unnecessary to have
steam flow typical of LOCA/ECCS
conditions. These are not heat transfer
tests. Once a reaction rate model is
developed using data from experiments
like these, the model should be
validated against transient tests under
LOCA conditions, as in the four
Zircaloy tests described in WCAP–7665
and the transient tests described in the
Cathcart-Pawel report.
Calculations were performed to assure
that there was adequate steam flow for
the MiniZWOK experiments used to
derive the Cathcart-Pawel correlation in
NUREG–17. These calculations are
described in the RES technical study.
An important argument for the
absence of steam starvation is how the
isothermal Cathcart-Pawel experiments
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 Federal Register / Vol. 70, No. 171 / Tuesday, September 6, 2005 / Rules and Regulations
described in NUREG–17 give consistent
results that support the parabolic/
Arrhenius behavior. This is also
discussed in the RES technical study.
Much of the petitioner’s criticism of
the Cathcart-Pawel work is related to a
comparison of MiniZWOK and
MaxiZWOK experimental conditions.
MiniZWOK was used to develop a
consistent set of data for correlation
development. Controlling sample
temperature by adjusting heater power
(MiniZWOK) was much more successful
than adjusting steam flow (MaxiZWOK).
As the petitioner notes, temperature
overshoot was a problem with
MaxiZWOK and at high temperatures
could have led to temperature runaway.
As noted previously, temperature
control is absolutely necessary in
reaction kinetics experiments such as
these. The petitioner implies that the
experimenters abandoned MaxiZWOK
in favor of MiniZWOK. Actually, the
isothermal MiniZWOK experiments
were essentially complete before the
MaxiZWOK experiments were begun.
Results from MaxiZWOK between 1652
°F and 1832 °F agreed well with
MiniZWOK data at the same
temperatures. Cathcart and Pawel state
that:
The very good agreement between these
two data sets is regarded as evidence that
steam flow rate and steam insertion
temperature do not affect significantly the
kinetics of the steam oxidation of Zircaloy, at
least in this temperature range.
Certainly, with steam velocities at
least an order of magnitude greater in
MaxiZWOK than MiniZWOK, the
potential for more rapid gas phase
diffusion of steam to the sample surface
‘‘mass transfer’’ is greater for
MaxiZWOK. But clearly this is not the
limiting phenomenon. This was
demonstrated by the good agreement
between MiniZWOK and MaxiZWOK
data and the good agreement of
MiniZWOK data to parabolic/Arrhenius
behavior. There is no evidence to
suggest that high ‘‘mass transfer
coefficients’’ in MaxiZWOK caused
temperature overshoot in MaxiZWOK at
1832°F, as the petitioner proposes. It is
true, as the petitioner suggests, that ‘‘[i]t
is not possible to achieve an isothermal
rate of oxidation of Zircaloy-4 if the
Zircaloy-4 is exposed to LOCA fluid
conditions at elevated conditions,’’ but
not for the reasons postulated by the
petitioner. Rather, large-break LOCA
reflood conditions are characterized by
constantly decreasing power (decay
heat) and increasing heat transfer
coefficients after a few seconds. Under
these conditions, isothermal conditions
are impossible. WCAP–7665 showed
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that this kind of heat transfer and power
behavior was universal for all tests done
under design basis conditions, and as a
result, these heat transfer tests did not
exhibit isothermal cladding temperature
behavior.
The petitioner implies that Cathcart
and Pawel’s statement, that scoping
tests on the effect of steam pressure
were in progress, is an admission of
inapplicability of their work. On the
contrary, the scoping work was
completed and subsequent work by
others has been undertaken to examine
pressure effects. The petitioner’s notion
that the authors’ statement about
ongoing work applies to very low steam
velocities is also unsupported.
Work in this area did not end in 1977.
The NRC, foreign partners, and the
industry have continued to conduct and
evaluate experimental and analytical
programs on fuel cladding behavior. As
in the case with many other research
activities and their link to the agency’s
regulatory framework, an important
objective of this work is the
confirmation of current § 50.46 criteria
and models and the development of
more realistic, performance-based, and
contemporary criteria and models. An
important link to the current work is the
extensive research reported by Cathcart
and Pawel.
The NRC disagrees with the
petitioner’s assertion that the disclaimer
in the introduction to NUREG–17 causes
the technical work to be inapplicable to
reactor regulation. The disclaimer
protects the United States Government
from potential litigation. It is not
intended to discredit the technical
validity of the work documented in
NUREG–17. As such, the disclaimer is
irrelevant to whether the NUREG–17
work is an adequate basis for reactor
regulation. That is a question that
should be decided solely on the
technical merits of the work.
The NRC found no technical basis in
the petition nor in NRC records to
support the assertion that the Regulatory
Guide 1.157 conditions for acceptance
of the use of ORNL/NUREG–17
information result in flawed evaluation
of ECCS performance.
Issue 3: Need for Further Analysis of
Appendix K Backup Data
In Section 3.4 of his petition, the
petitioner quotes from the AEC decision
on the ECCS rulemaking [See
Rulemaking Hearing, Acceptance
Criteria for Emergency Core Cooling
Systems for Light-Water Cooled Nuclear
Power Reactors, RM–50–1, CLI–73–39,
6AEC1085, at 1124]: ‘‘It is apparent,
however, that more experiments with
Zircaloy cladding are needed to
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52897
overcome the impression left from run
9573.’’ The petitioner claims that such
experiments have not been performed
and are necessary. The NRC disagrees.
Run 9573 refers to one of four
Zircaloy clad FLECHT experiments
performed in 1969 and reported in
WCAP–7665. The ‘‘impression’’ referred
to by the AEC Commissioners in 1973
appears to be the fact that run 9573
indicates lower ‘‘measured’’ heat
transfer coefficients than the other three
Zircaloy clad tests reported in WCAP–
7665 when compared to the equivalent
stainless steel tests. This is not a
concern about the zirconium-water
reaction models. The AEC
Commissioners believed that this
anomaly could be cleared up with more
experiments on Zircaloy cladding. Some
of the anomaly can probably be
explained by a deficiency in the data
reduction process. As will be discussed
later, additional Zircaloy clad tests were
performed in the 1980s.
Regarding the data reduction process,
heat transfer coefficients are not directly
measurable quantities. They must be
calculated from measured temperatures,
known heat sources, and known thermal
properties. WCAP–7665 describes the
heat transfer data reduction process
using the DATAR code. For these
experiments, the decay heat simulation
was well known, as was the time of
heater failure. However, the heat source,
due to the zirconium-water reaction,
had to be estimated in some way. The
Baker-Just correlation was used for that
purpose. Because of its conservatism,
the Baker-Just correlation overestimates
the amount of reaction and the
associated heat generation rate. At 21
locations on 19 rods among the four
Zircaloy tests, post-test oxide thickness
measurements were made.
Westinghouse applied the Baker-Just
correlation to each temperature
transient measured at or very near to
each oxide thickness measurement. The
comparison between predicted and
measured oxide thickness was
presented in Figure B–12 of WCAP–
7665. The Baker-Just calculated oxide
thickness is about 1.6 times the
measured value. Thus for this data set,
the Baker-Just correlation overpredicts
the data by about 60 percent, which is
quite conservative.
The NRC obtained tabular time/
temperature data from Westinghouse for
19 of the 21 locations analyzed by
Westinghouse for the four Zircaloy
FLECHT tests. The Baker-Just
correlation was applied to these 19 data
sets as a check on the analysis in
WCAP–7665. The RES technical study
clearly demonstrates that the analysis in
WCAP–7665 is correct and that the
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 52898 Federal Register / Vol. 70, No. 171 / Tuesday, September 6, 2005 / Rules and Regulations
Baker-Just correlation is conservative
even under the severe conditions of run
9573.
The petitioner asserts that a detailed
thermal-hydraulic analysis of run 9573,
including evaluation of the heating from
Zircaloy-water reactions, was never
performed. Contrary to that assertion,
not only was an evaluation of the
heating from Zircaloy-water reaction
performed for run 9573, it was done for
all four Zircaloy tests. Unfortunately,
using the conservative Baker-Just
correlation to estimate the zirconium-
water heat release results is an
overestimation of the derived heat
transfer coefficients. Thirty-five years
later, it would be difficult to replicate
the DATAR code, substitute a better
metal-water model, and re-derive the
heat transfer coefficients. The difficulty
would be in addition to the significant
monetary expense of conducting high-
temperature Zircaloy tests and would
have marginal benefit in terms of
increased understanding of large-break
LOCA heat transfer and metal-water
reaction kinetics. The current programs
being conducted at Pennsylvania State
University and Argonne National
Laboratory are far more cost-effective.
High-temperature tests similar to run
9573 would require rod bundle powers
well outside the range of operation of
any current or proposed pressurized
water reactors (PWRs) and would
produce very little useful heat transfer
information. Therefore, the NRC does
not believe that such tests are necessary.
The petitioner states that more
experiments with Zircaloy cladding
have not been conducted on the scale
necessary to overcome the impression
left from run 9573. The NRC disagrees.
In fact additional Zircaloy tests have
been performed. In the early 1980s, the
NRC contracted with National Research
Universal (NRU) at Chalk River,
Ontario, Canada to run a series of LOCA
tests in the NRU reactor. More than 50
tests were conducted to evaluate the
thermal-hydraulic and mechanical
deformation behavior of a full-length 32-
rod nuclear bundle during the heatup,
reflood, and quench phases of a large-
break LOCA. The NRC is reviewing the
data from this program to determine its
value for assessing the current
generation of codes such as TRAC-M
(now renamed TRACE).
In assessing the need for further
experiments like the Zircaloy-clad
FLECHT tests, it is important to
understand the past and current role of
rod bundle reflood heat transfer tests. In
the late 1960s, a mechanistic
understanding of reflood heat transfer
did not exist. To develop heat transfer
models as expeditiously as possible, the
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Atomic Energy Commission (AEC),
Westinghouse, and Electric Power
Research Institute (EPRI), cooperatively
developed the PWR FLECHT program.
The principal objective was to
determine reflood heat transfer
coefficients as a function of key initial
and boundary conditions, rod elevation,
and time after the beginning of reflood
and to develop empirical correlations
based on that dependency. As long as a
sufficiently large matrix of tests was
performed with full-scale rod bundles,
there was no great need for a
comprehensive mechanistic
understanding. The key parameters
were:
A. Pressure
B. Peak power
C. Decay power
D. Flooding rate
E. Inlet subcooling
F. Initial temperature
G. Bundle size
H. Cladding material
I. Housing temperature
When nuclear plant behavior and
design conditions are outside the
envelope defined by these test
parameters or the design of the
experimental system, there is no basis
for extrapolation, since the derived heat
transfer models are not necessarily
based on the physical models governing
the reflood heat transfer processes. For
the very empirical process used in the
early FLECHT experiments, limited
effort was expended obtaining data
needed for development of mechanistic
physical models. It would have been
impractical to obtain sufficient Zircaloy
heat transfer coefficient data for the
empirical process used with the early
FLECHT experiments.
As the FLECHT program and other
rod bundle reflood heat transfer
programs have progressed over the last
30 years, more information appropriate
for mechanistic model development has
been obtained. As better mechanistic
models are developed, careful
extrapolation has a better chance of
success, and the role of experiments like
FLECHT has shifted from model
development to developmental
assessment. In fact, many of the
FLECHT-SEASET experiments are used
to assess the new code models. As
mentioned previously, the NRC is
reviewing the NRU Zircaloy-clad
nuclear fuel bundle test results to
establish their value for further code
assessment.
Conclusions
The NRC investigated each of the
petitioner’s key concerns. The NRC
concludes that Appendix K of 10 CFR
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Part 50 and the existing guidance on
best-estimate ECCS evaluation models
are adequate to assess ECCS
performance for U.S. light water reactors
(LWRs) using Zircaloy-clad UO2 at
burnup levels currently permitted by
regulations. This general conclusion is
based on the following considerations:
The Baker-Just correlation using the
current range of parameter inputs is
conservative and adequate to assess
Appendix K ECCS performance.
Virtually every data set published since
the Baker-Just correlation was
developed has clearly demonstrated the
conservatism of the correlation for the
temperature range important to clad
oxidation calculations for LOCAs.
The parabolic/Arrhenius behavior of
the Cathcart-Pawel isothermal
experiments confirmed that there was
adequate availability of steam. An NRC
analysis confirms the ORNL/ANL
assessment that the Cathcart-Pawel
isothermal experiments were not steam
starved by at least two orders of
magnitude. Therefore, the experimental
data is valid.
NRC has continued to study complex
thermal hydraulic effects on ECCS heat
transfer processes during LOCA
accident conditions consistent with
Commission direction. As part of that
initiative, the NRC funded more than 50
Zircaloy-clad nuclear fueled bundle
reflood experiments at the NRU reactor.
These experiments evaluated fuel rod
and heat transfer behavior but did not
include metallurgical examination to
evaluate oxidation behavior. The NRC is
continuing to conduct and evaluate
experimental and analytical programs
on fuel cladding behavior.
The petitioner did not take into
account Westinghouse’s metallurgical
analyses performed on the cladding for
all four FLECHT Zircaloy-clad
experiments reported in WCAP–7665.
The petitioner also ignored the
Westinghouse application of the Baker-
Just correlation to these experiments,
which had the ‘‘complex thermal
hydraulic phenomena’’ deemed
important by the petitioner. This
application of the correlation to the
metallurgical data clearly demonstrates
the conservatism of the Baker-Just
correlation for 21 typical temperature
transients. The NRC also applied the
Baker-Just correlation to the FLECHT
Zircaloy experiments with nearly
identical results, confirming the WCAP–
7665 results.
For the development of oxidation
correlations, limited by oxygen
diffusion into the metal, well-
characterized isothermal tests are more
important than the complex thermal
hydraulics suggested by the petitioner.
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 Federal Register / Vol. 70, No. 171 / Tuesday, September 6, 2005 / Rules and Regulations
The petitioner’s suggested use of
complex thermal-hydraulic conditions
would be counter-productive in reaction
kinetics tests because temperature
control is required to develop a
consistent set of data for correlation
development. Isothermal tests allow this
needed temperature control. It is more
appropriate to apply the developed
correlations to more prototypic
transients (including complex thermal
hydraulic conditions) to verify that the
proposed phenomena embodied in the
correlations are indeed limiting. This is
what was done by Westinghouse in
WCAP–7665, by Cathcart and Pawel in
NUREG–17 and by the NRC in its
technical safety analysis of PRM–50–76.
The NRC applied the Cathcart-Pawel
oxygen uptake and ZrO2 thickness
equations to the four FLECHT Zircaloy
experiments, confirming the best-
estimate behavior of the Cathcart-Pawel
equations for large-break LOCA reflood
transients.
Cathcart and Pawel applied their
oxide thickness equation, using the
BILD5 program, to 15 of their transient
temperature experiments as described in
ORNL/NUREG–17. The results showed
that the correlation, based on numerous
isothermal experiments, was
conservative or best-estimate when
applied to this transient data set.
Petitioner’s Public Comments
The petitioner submitted two public
comment letters in which he again
asserted that the Baker-Just and
Cathcart-Pawel equations are grossly
misapplied by the NRC. The first
comment letter basically repeated the
arguments in the petition. No new
technical information was supplied. The
second comment letter introduced the
issue of severe fouling, which was the
subject of PRM–50–78 and addressed by
the staff’s evaluation of that petition for
rulemaking. Other issues addressed in
the second letter are related to the issues
already discussed in this document, and
therefore, no further response is
necessary.
Reasons for Denial
For the reasons cited in this
document, the Commission is denying
the petition for rulemaking (PRM–50–
76) submitted by Mr. Robert Leyse. The
NRC believes that the requested
rulemaking would not make a
significant contribution to maintaining
safety because current regulations and
regulatory guidance already adequately
address the evaluation of performance
of the ECCS. No data or evidence was
provided by the petitioner or found in
NRC records to suggest that the
research, calculation methods, or data
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used to support ECCS performance
evaluations were sufficiently flawed so
as to create significant safety problems.
NRC’s technical safety analysis
demonstrates that current procedures
for evaluating performance of ECCS are
based on sound science and that no
amendments to the NRC’s regulations
and guidance documents are necessary.
Additionally, the petitioner has not
shown, nor has the NRC found, the
existence of any safety issues regarding
calculation methods or data used to
support ECCS performance evaluations
that would compromise the secure use
of licensed radioactive material. The
proposed revisions would not improve
efficiency, effectiveness, and realism
because licensees and the NRC would
be required to generate additional
information (as part of the evaluation of
ECCS performance) that has no safety
value and does not significantly
improve realism.
Dated at Rockville, Maryland, this 26th day
of August, 2005.
For the Nuclear Regulatory Commission.
Annette L. Vietti-Cook,
Secretary of the Commission.
[FR Doc. 05–17589 Filed 9–2–05; 8:45 am]
BILLING CODE 7590–01–P
DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 39
[Docket No. FAA–2004–18877; Directorate
Identifier 2002–NM–340–AD; Amendment
39–14248; AD 2005–18–08]
RIN 2120–AA64
Airworthiness Directives; Boeing
Model 737–100, –200, –200C, and –300
Series Airplanes
AGENCY: Federal Aviation
Administration (FAA), Department of
Transportation (DOT).
ACTION: Final rule.
SUMMARY: The FAA is adopting a new
airworthiness directive (AD) for certain
Boeing Model 737–100, –200, –200C,
and –300 series airplanes. This AD
requires repetitive detailed inspections
to detect discrepancies of the retaining
pin lugs on the support fitting of the
main landing gear (MLG) beam, and
rework of the support fitting, or
replacement of the fitting if necessary.
This AD is prompted by reports of
discrepancies of the lugs. We are issuing
this AD to prevent separation of the
support beam of the MLG from the rear
spar, which could cause cracking of the
MLG support fitting and a consequent
PO 00000 Frm 00007 Fmt 4700 Sfmt 4700 E:\FR\FM\06SER1.SGM
52899
leak in the wing fuel tank or collapse of
the MLG.
DATES: This AD becomes effective
October 11, 2005.
The incorporation by reference of
certain publications listed in the AD is
approved by the Director of the Federal
Register as of October 11, 2005.
ADDRESSES: For service information
identified in this AD, contact Boeing
Commercial Airplanes, P.O. Box 3707,
Seattle, Washington 98124–2207.
Docket: The AD docket contains the
proposed AD, comments, and any final
disposition. You can examine the AD
docket on the Internet at http://
dms.dot.gov, or in person at the Docket
Management Facility office between 9
a.m. and 5 p.m., Monday through
Friday, except Federal holidays. The
Docket Management Facility office
(telephone (800) 647–5227) is located on
the plaza level of the Nassif Building at
the U.S. Department of Transportation,
400 Seventh Street, SW., room PL–401,
Washington, DC. This docket number is
FAA–2004–18877; the directorate
identifier for this docket is 2002–NM–
340–AD.
FOR FURTHER INFORMATION CONTACT:
Robert C. Hardwick, Aerospace
Engineer, Airframe Branch, ANM–120S,
FAA, Seattle Aircraft Certification
Office, 1601 Lind Avenue, SW., Renton,
Washington 98055–4056; telephone
(425) 917–6457; fax (425) 917–6590.
SUPPLEMENTARY INFORMATION: The FAA
proposed to amend 14 CFR part 39 with
an AD for certain Boeing Model 737–
100, –200, –200C, and –300 series
airplanes. That action, published in the
Federal Register on August 17, 2004 (69
FR 51017), proposed to require
repetitive detailed inspections to detect
discrepancies of the retaining pin lugs
on the support fitting of the main
landing gear (MLG) beam, and rework of
the support fitting or replacement of the
fitting if necessary.
Comments
We provided the public the
opportunity to participate in the
development of this AD. We have
considered the comments that have
been submitted on the proposed AD.
Agreement With the Proposed AD
One commenter, the manufacturer,
agrees with the proposed AD.
Conditional Agreement With the
Proposed AD
One commenter, an operator, agrees
with the proposed AD provided that
there are adequate parts available if the
discrepant condition is found.
The FAA agrees that adequate
availability of parts is necessary. We
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